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UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
Release No. 36679 / January 4, 1996
ADMINISTRATIVE PROCEEDING
File No. 3-8916
______________________________
: ORDER INSTITUTING PUBLIC
: ADMINISTRATIVE PROCEEDING
In the Matter of : PURSUANT TO SECTIONS 15(b) AND
: 19(h) OF THE SECURITIES
BRADFORD P. GILLINGHAM, : EXCHANGE ACT OF 1934, MAKING
: FINDINGS AND IMPOSING
Respondent : REMEDIAL SANCTIONS
______________________________:
I.
The Securities and Exchange Commission ("Commission") deems
it appropriate and in the public interest to institute a public
administrative proceeding pursuant to Sections 15(b) and 19(h) of
the Securities Exchange Act of 1934 ("Exchange Act") against
Bradford P. Gillingham ("Gillingham" or "Respondent").
In anticipation of the institution of this proceeding, the
Respondent has submitted an Offer of Settlement ("Offer") to the
Commission, which the Commission has determined to accept.
Solely for the purpose of this proceeding and any other
proceeding brought by or on behalf of the Commission or in which
the Commission is a party, the Respondent, admitting the findings
contained herein, consents to the entry of the findings and
remedial sanctions set forth below.
Accordingly, IT IS ORDERED that a proceeding pursuant to
Sections 15(b) and 19(h) of the Exchange Act be, and hereby is,
instituted.
II.
On the basis of this Order and the Respondent's Offer, the
Commission finds that:
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A. From December of 1979 through the present, Gillingham
is, and has been, a registered representative of various
securities broker-dealers registered with the Commission.
B. On November 17, 1995, in the criminal matter entitled
United States of America v. Bradford P. Gillingham, CR 95-0076
CAL (N.D. Cal.), Gillingham was convicted of one count of
violating 18 U.S.C. Section1001 in connection with testifying
falsely before the staff of the Commission during an
investigation.
C. The Superseding Information in the criminal matter
alleged that Gillingham willfully and knowingly made false
statements of material facts to the staff of the Commission
during an investigation after having taken an oath to testify
truthfully. Specifically, the Superseding Information alleged
that Gillingham denied having a conversation with a mid-level
manager of a certain publicly-held corporation regarding the
business of the corporation and denied receiving material non-
public information regarding the projected revenues and book-to-
bill ratio of the corporation from that manager, while knowing,
in fact, that he had had such a conversation with the manager and
that such information was conveyed.
III.
Based upon the foregoing, the Commission deems it
appropriate and in the public interest to impose the sanctions
specified by the Respondent in his Offer.
Accordingly, IT IS HEREBY ORDERED that, effective
immediately, Bradford P. Gillingham be, and hereby is, barred
from association with any broker, dealer, municipal securities
dealer, investment adviser, or investment company.
By the Commission.
Jonathan G. Katz
Secretary
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